Each of the
factual findings alleged to be erroneous: (1) involves the application of complex econometric models; (2) involves reliance on
data not derived from the carriers» actual experience; and (3)
requires extrapolation from
data regarding the general population to
data regarding persons with such severe disabilities that they
require additional seating.
In December 14, 2001 and July 11, 2002 letters, the United States Department of Justice and the Federal Trade Commission jointly urged the Bar to reconsider its opinions
requiring lawyers to be physically present during real estate closings and refinancings, stating that the opinions would «likely harm the public,» and that the Bar «provided no
factual data to support» its position.